Judicial review of eligibility conditions cannot override a plausible administrative view where language equivalence is not proved.

A university one-year part-time Certificate Course in Bengali did not satisfy the language requirement under Rule 5(c) of the West Bengal School Service Commission Rules, 2007 or the advertisement for appointment as Assistant Teacher in a Bengali-medium school. The prescribed standard required the relevant medium language at secondary, higher secondary, graduation, or a later higher level of education, and no document showed that the certificate course was equivalent to a post-higher-secondary qualification. The Supreme Court held that the High Court exceeded the limits of judicial review by substituting its view for a plausible administrative interpretation of the eligibility condition. The candidate was therefore ineligible, and the High Court's interference was unsustainable.

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Issues: Whether a one-year part-time Certificate Course in Bengali from a university satisfied the language requirement under Rule 5(c) of the West Bengal School Service Commission (Selection of Persons for Appointment to the Post of Teachers) Rules, 2007 and the advertisement, so as to entitle the candidate to appointment as Assistant Teacher in a Bengali-medium school.

Analysis: The eligibility condition required the candidate to have the relevant medium language at the secondary, higher secondary, graduation, or a subsequent higher level of education. The Court held that a university certificate course undertaken by a graduate was not shown to be of a level higher than higher secondary or equivalent, and the candidate produced no document certifying equivalence to post-higher-secondary Bengali. The High Court, in treating the certificate course as sufficient, exceeded the its of judicial review and effectively sat in appeal over an administrative decision. The authority's interpretation that the certificate course did not meet the prescribed standard was a plausible view and not one warranting interference under Article 226.

Conclusion: The candidate did not satisfy the eligibility requirement under Rule 5(c), and the High Court's interference was unsustainable.

Final Conclusion: The impugned judgment and order were set aside, and the appeal succeeded.

Ratio Decidendi: In judicial review, a writ court will not substitute its own view for a plausible administrative interpretation of eligibility conditions, and a language certificate course will not satisfy a prescribed higher-level language requirement unless its equivalence is shown.

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